OPINION AND ORDER
SOTOMAYOR, District Judge.
Plaintiffs Alfred Toker and Annette Toker seek tax refunds, from the defendant Internal Revenue Service, for the years 1982, 1983, and 1984. According to the allegations set forth in their Complaint, the IRS mistakenly disallowed certain deductions, claimed by the Tokers for each of those years, in connection with the couple's partnership interest in "Term Associates Partnership." The Tokers contend that...
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